A recurring key question is whether a food product can have a picture of the fruit in question on it. When do you have to add "flavor"? The Dutch Food and Consumer Product Safety Authority (NVWA) has recently issued a manual that clarifies how the NVWA will enforce [1].

In short, the new 'pictorials' rules: if the product contains real fruit, or fruit extract, fruit concentrate or fruit juice, you may depict the fruit on the packaging. So strawberry yogurt with a picture of a tasty strawberry or grape juice with a bunch of grapes.

When using only a flavoring, you may include the image of the ingredient under the condition that the word "flavor" appears in the vicinity: so for example: "with vanilla flavor". This also applies to natural (x)-flavors.
And what if real fruit (extract/concentrate/juice) is used in combination with a flavoring? Then two variants are possible:
i) if the fruit (or the ingredient/juice/concentrate/extract) actually adds flavor then no flavor disclaimer is needed;
ii) and otherwise a flavor disclaimer is also required with the image.

Many sensory tests will undoubtedly follow in the future.

Pretty handy this kind of thumb rules. But beware: it's always about concrete packaging. Color, shape, text, image, proportionality, everything counts. The basic question is: what does the average consumer think?

Ebba Hoogenraad

23 June 2021